The EMF Safety Network alleges that PG&E Smart Meters violate one or more FCC conditions that determine RF exposure compliance. The FCC Grants of Equipment Authorization, which govern the rules upon which FCC compliance is based, warns that RF exposure compliance depends on specific conditions. The conditions include one or more of the following, depending on the specific make and model of Smart Meter.

• limited single module approval requires professional installation;

• antenna(s) must provide a separation distance of at least 20 cm from all persons;

• antenna(s) must not be co-located or operating in conjunction with any other antenna or transmitter;

• end-users and installers must be provided with antenna installation and transmitter operating conditions for satisfying RF exposure compliance

Smart Meters are widely co-located in banks of multiple meters. Co-location also occurs within Smart Meters because electric Smart Meters include at least two internal RF antennas. One antenna is used for the mesh network system and the other is for the Home Area Network (HAN) systems. Antennas are designed to work in conjunction with the HAN and RF appliances and with other Smart Meters in a mesh network. Antennas have separate Grants of Equipment Authorization, which suggests that manufacturers have tested antennas in isolation and individually, and not in combination, which is how the Smart Meter and the Smart Grid system were designed to operate….

…Network alleges one or more FCC exposure compliance violations for the following meters PG&E is deploying: FCC ID numbers: OWS-NIC514, OWS-NIC507, and LLB6327PWM.

Furthermore, “antenna(s) must provide a separation distance of at least 20 cm (8 in.) from all persons,” yet there are no warning labels on Smart Meters, and PG&E has actually encouraged people to get close to their meters to read them.

Many Smart Meters are installed within 20 cm of public access. In some cases the meters are installed inside homes and businesses. In many situations Smart Meters are easily accessible to the public. This rule is clearly violated.

Violations of FCC safety limits for uncontrolled public access are identified at distances out to a distance of more than one foot for a single meter, and several feet for multiple meters, even under the most restrictive FCC formula using only a 60% reflection factor.

“The emissions from one meter are strong enough that the public is put at risk from exposures outward from the meter from approximately one foot to over six feet, depending on the reflection factor,” says Cindy Sage, Sage Associates. “For multiple meters at the same location, the zone of impact where FCC limits may be violated is somewhere between three feet and 19 feet, depending on the reflection factor.”